A Nigerian woman from Delta State sought international protection in Italy, but the Territorial Commission of Trapani rejected her request. The applicant brought the case before the Palermo Court of Appeal, which investigated the several distinguishing indicators of human trafficking, including trafficking for sexual exploitation.

The court considered whether the applicant met the indicators of human trafficking outlined in the Guidelines for Territorial Commissions for the Recognition of International Protection. The court highlighted that the fragmented testimony revealed throughout the proceedings conforms to the reluctance and resistance that many victims have in telling their stories.

It added that age, coming from a disadvantaged socioeconomic background, the family condition of marginalisation, the further marginalisation suffered by the family as a result of refusing an arranged marriage, and abandonment by the first husband represent personal conditions in accordance with the guidelines.

The organisation of the journey through acquaintances with whom the relationship was not known, being passed from person to person, the migratory route, the exploitation along the way and the non-return of the passport were further identified as indicators of human trafficking.

Moreover, it added that according to the EASO COI report on trafficking of human beings from Nigeria for the purpose of sexual exploitation, women from the southern states of Edo and Delta are predominant profiles of victims of human trafficking. The 2021 EUAA report EUAA COI report: Nigeria – Trafficking in Human Beings, 2021, further confirmed that Nigerian women continued to make up the majority of recognised victims of trafficking in the EU (92%) between 2017 and 2018. 

Based on the evidence, the Palermo Court of Appeal determined that the applicant was a victim of international human trafficking for sexual exploitation. In conducting a risk assessment in the event of return to Nigeria, the court ruled that the applicant would be at risk of stigmatisation and re-trafficking. As a result, the court granted the applicant's appeal, granted refugee status and the right to remain in Italy.

The court has also consulted other EUAA COI reports from 2015 on Nigeria. 

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